Application of ICH Q12 Tools and Enablers Post-Approval Lifecycle - - PowerPoint PPT Presentation

Joint BWP/QWP/GMDP IWG – Industry European Workshop on Lifecycle Management

Application of ICH Q12 Tools and Enablers

Post-Approval Lifecycle Management Protocols

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Outline

• Introduction: evolution of PACMP concept
• Expanded (multi-site, multi-product) change

management protocols (Roche, presenter: Wassim Nashabeh)

• Risk-based (step-2) Variation classification in

case of changes for biological products in accordance with an approved Post Approval Change Management Protocol (J&J/ Janssen, presenter: Ronald Imhoff)

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Introduction: ICH Q12 – evolution of PACMP concept

• Current Q12 draft GL contains evolving concepts regarding

PACMPs that warrant a further discussion based on examples:

1 2

Example 1: Roche/Genentech

• Site Transfers under an “Expanded Change

Management Protocol”: multi-site/ multi- product approach (presenter: Wassim Nashabeh)

• Key Question: what needs to be in ICH Q12

to enable such expanded approaches in all regions?

Expanded Protocols - Outline

• Introduction/ background
• Case Study: Considerations for expanded post-approval change management

protocol (ePACMP) for Site Transfer: – Scope – Quality Risk Management (QRM) – Inspection Management/ PQS – Comparability – Validation

• Summary

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Site Transfers are required to support network mobility and mitigate risk post-approval

• To meet world-wide demand for the drug

– Manufacturing plant capacity is often limited and must be balanced across a broad network of facilities and products

• To mitigate risk associated with single sourcing to ensure supply

to patients

– Reduce Risk for out of stock situations – Safety backup / risk mitigation, in case one site cannot produce material for various reasons

• Natural disasters
• Loss by fire
• Equipment break-down
• Flexibility to supply all markets

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Site Transfer of Product A to Site Y Leveraging ‘traditional’ protocol in the US & EU

Product A

Execute transfer per defined requirements in protocol

Drug Substance Receiving Site Y D

Supplement/ variation with data demonstrating acceptance criteria met

Drug Substance Donor Site X A B C

Submit protocol describing site transfer acceptance criteria for product- site combination

A

Defined business need

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Example (EU): Biologics DS manufacturing site transfer - Benefit of PACMP Approach vs. „Traditional“ Approach*

• Up to 5 months faster approval of

the site change using a PACMP (time benefit similar in US)

*Note: approval timelines for type II variation in this scheme include positive CHMP opinion and Commission Decision

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PACMP

Site Transfer Leveraging expanded Comparability Protocol (eCP) – a reflection of the experience with US-FDA

A network of Drug Substance Donor Sites B C D A

Execute transfer per defined requirements in eCP

B C D Site Y or Z Site X or Z Site X or Z Site X or Y Site X Site Z SiteY A network of Drug Substance Receiving Sites

Submit eCP describing site transfer acceptance criteria broadly for both Site and Product CBE-30 Supplement with data demonstrating acceptance criteria met Potential Future Network Requirements

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A

eCP Site Transfer General Strategic Framework

Scope and Limitations

Acceptance Criteria cGMP Quality Risk Management eCP

Strategy & Scope of the Site Transfer eCP

• The primary objective of the Site Transfer eCP is to support the mobility across

drug substance manufacturing sites, i.e. transfer from one donor site to one or more recipient site(s): – Several monoclonal antibodies – Several sites, incl. CMOs (sites already licensed with appropriate inspection record) – Reduces the number of regulatory submissions of similar content and drives consistency – Effectively leverages concepts of Quality Risk Management and ICH Q9 – Builds upon company’s experience with site transfers across products and sites

• Scope excludes opportunistic significant process changes; typical process adaptions

linked to scale and equipment differences in scope

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Site Transfer Risk Assessment Considerations

• Performed for each site transfer
• Identifies, scores, and documents the potential hazard and harm associated

with each unit operation and process change, as well as the prevention and detection controls

• Accounts for known elements of the process

– Robustness – Existing controls – Potential impact to product quality

• Considers the subjectivity of risk assessment

– Team – Facilitator – Training – Consistency and calibration of risks – Severity, Occurrence, Detection scoring definitions

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Site Transfer Risk Assessment Example

Failure modes prospectively identified and assessed by team of experts

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Note: Risk Priority Number (RPN) is the product of the Primary Risk Number (PRN) and the score for probability of detection.

Risk Prioritization Matrix

Identified thresholds of risk acceptability incorporated in overall applicability to Site Transfer eCP

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Inspection Management (overlap with Inspection/ PQS session)

Site Inspection Assessment:

• Risk-ranking tool provides a generic approach to assess site

and process risks for technical transfers, incl. CMOs

• Will help to understand the level of overall inspectional risk

at the recipient site

• Will serve as an evaluation of the GMP compliance status of

the recipient site

• Highlights the importance of assessor-inspector

collaboration

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Site inspection assessment - risk ranking tool (overlap with Inspection/ PQS session)

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Ris isk factors rs

Fac acil ilit ity CMO vs. internal network Facility experience Inspection history etc. Product ct Raw materials used

• Tech. Transfer experience

Product knowledge etc. Proces ess Similarity to existing process Process knowledge Manufacturing complexity etc. Expe perienc nce Workforce experience Quality system Technology competence etc.

Ri Risk lev evel el Submissi ssion req require remen ents

lo low In scope of protocol, moderate change submission (CBE-30, Ib var.); stress stability data only mediu ium In scope of protocol, moderate change submission (CBE-30, Ib var.), incl. 6-month real-time stability data high gh Outside of scope of protocol, i.e. major change submission

Comparability Approach

Category Components A The basic package:

• QC lot release data, including potency
• extended physico-chemical characterization methods
• accelerated degradation, with real-time stability and commitments
• process-related impurity levels (host cell proteins, DNA, Protein

A) A+B Biological characterization:

• Fcγ receptor assays, FcRn, ADCC
• Biacore or other binding assays

A+B+C Animal PK or PK/PD studies:

• rodent PK may suffice
• may need primates for PD

A+B+C+D Clinical PK (comparability bridging study):

• direct comparison to licensed process material in human subjects

A+B+C+E Clinical experience or efficacy

• may need to confirm efficacy, lack of AEs, lack of immunogenicity
• might be a “clinical experience” study, or head-to-head vs.

licensed process

Transfer to a new site with facility fit changes with no expected change to product characteristics Out of scope

• f protocol

concept

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Overall Comparability Plan for Site Transfer

• Drug Substance must meet all release and in-process specifications, as well as

comparability acceptance criteria (e.g., tolerance intervals [TI, 95/99]) derived from entire manufacturing history – Specifications provide assurances of product quality – Comparability acceptance criteria provide assurances of consistency with previous processes

• Analytical profiles from selected characterization tests are consistent with pre-change

material in side-by-side comparisons

• Process performance attributes

– Cell culture performance – Purification process yields – Impurities levels

• Drug Substance degradation studies consistent with pre-change material

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Submissions without Real Time Stability Data (link to lifecycle strategy)

• Traditionally rate-limiting to site transfer timelines, this approach speeds time

to regulatory submission and introduction to the market

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Process validation

• Provides an overview of validation project plan and validation

master plan for the site transfer in accordance to the current PQS system

• Summary of validation studies performed to support the site

transfers, e.g. studies adopted from donor site and new studies at the recipient site will be part of the step-2 implementation submissions (CBE-30 or type Ib)

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Summary

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eCP CP St Strat ategic ic C Component nt ePAC ACMP ste step 1 1 cont ntent nts (registr trati tion o

• f proto

tocol) ePAC ACMP ste step 2 2 cont ntent nts (chan ange im impl plement ntat ation) Overall St Strat ategy ( (Sc Scope and and Lim imit itatio ions) Defined scope and limitations Demonstrate requirements of scope met, including process changes associated with transfer QRM RM Description of QRM program and approach to site transfer risk assessment Documented risk control strategy and executed risk management report summary Compar arabil ility & & St Stab abil ilit ity Comparability plan, real-time stability commitments and acceptance criteria (pr product Sp Specif ific ic) Data demonstrating that acceptance criteria are met Process V Val alid idatio ion Overview of validation program Summary of facility/equipment differences and applicable validation; Val alid idat ation s n summar ary data support the process, facility/equipment, and method transfer Ins nspe pection Description of Site inspection assessment - risk ranking tool Outcome of inspection risk ranking tool defines actual change submission requirements

Example 2: J&J/ Janssen

• Risk-based (step-2) Variation classification in

case of changes for biological products in accordance with an approved Post Approval Change Management Protocol (presenter: Ronald Imhoff)

Current PACMP procedure for chemical and biological products

Why is step 2 for biologal products per definition IB ?

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Introduction: ICH Q12 – evolution of PACMP concept

• Current ICH Q12 draft GL contains new concepts regarding

PACMPs that warrant a further discussion based on examples:

2

• The use of a PACMP is enabled through an effective quality risk

management system (ICH Q9) and change management system as part of a sound pharmaceutical quality system (ICH Q10).

• Components of a PACMP include the following elements:

– A detailed description, including a rationale, of the proposed change(s). The differences before and after the proposed change should be clearly highlighted. – Specific tests and studies to be performed, such as: characterization, release, stability as appropriate, in-process controls. The PACMP should include a description of the analytical procedures and proposed acceptance criteria for each test or study. – A quality risk management plan to assess the impact on product quality following implementation of the change(s), and if multiple changes are to be implemented, addressing the potential risk from the cumulative effect of multiple changes and/or how they are linked. – Supportive data from previous experience with the same or similar products related to: development, manufacturing, characterization, release, and stability to allow for risk mitigation – Discussion on the appropriateness of the approved control strategy to oversee the planned changes – Proposed reporting category for the implementation of step 2 of the PACMP

Examples of PACMP

Type of change Risk level

Reprocessing: re-filtration (0.45 and 0.2 µm in series) of Protein A clarified harvest in the event of a filter integrity failure Very Low Reprocessing: Repeating the viral removal filtration in the event of a filter integrity failure Low Reprocessing: Re-concentration in the event of over-dilution in the Concentration / Diafiltration manufacturing step Low Scale up: Change in size (width) of chromatography column. No impact on Critical Process Parameters (established condition) Very Low Addition of drug substance manufacturing site (within company). No change in manufacturing process. New site already inspected by an European Inspectorate Medium

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Reprocessing: Re-filtration of Protein A clarified harvest in the event of a filter integrity failure

PACMP (step 1) contains:

– Description of the change – Data from reduced scale studies; 2 successful independent filtrations – Commitment to perform one commercial scale study – Proposed tests with acceptance criteria – Risk assesment – Commitment that reprocessing is within established hold time

• Does this require review of the results by the Agency (step 2 )

before the change can be implemented?

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Proposed reporting category (step 2) based on risk assessment taking into account amongst others

• complexity of the change
• available (reduced scale) data to support the proposed change
• impact on product quality (CQA/CPP/CMA)
• product and process understanding
• status of PQS

Risk level Variation classification for step 2 Very low Do and Record (PQS & Product Quality Review) Low Do and Tell: Type IA Medium Do and Tell: Type IAIN High Tell and Do: Type IB

Proposed variation classification for step 2

• f the PACMP

Type of change Risk level Risk-based Variation classification . How to file the data?

Reprocessing: re-filtration (0.45 and 0.2 µm in series) of Protein A clarified harvest in the event

• f a filter integrity failure

Very Low Do and Record (PQS & Product Quality Review)

Reprocessing: Repeating the viral removal filtration in the event of a filter integrity failure

Low Do and Tell: Type IA

Reprocessing: Re-concentration in the event of

• ver-dilution in the Concentration / Diafiltration

manufacturing step

Low Do and Tell: Type IA

Addition of drug substance manufacturing site (within company). No change in manufacturing process. New site already inspected by an European Inspectorate

Medium Do and Tell: Type IAIN

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Proposed variation classification for step 2

• f the PACMP

Type of change Risk level Risk-based Variation classification . How to file the data?

Scale up: Change in size (width) of chromatography column. No impact on Critical Process Parameters (established condition)

Very low Do and Record (PQS & APR)

Change in anion exchange resin (chromatography column). Has impact on Critical Process Parameters (established condition)

Low Do and Tell: Type IA

Major change in fermentation process (continuous perfusion to fed batch) Has impact on Critical Process Parameters (established condition)

High Tell and Do: Type IB

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Summary

• The current PACMP procedure where step 2 for biological

products is per definition a type IB variation is too restrictive.

• The variation classification for step 2 proposed in step 1 (type

II variation) should be risk-based. Options are do and record (PQS), do and tell (type IA or IAIN) and tell and do (IB)

• This principle could also be applicable for chemical

substances.

Questions

• The proposed reporting category for step 2 should be risk based.

What would be an appropriate tool for this risk evaluation and how is the reporting category then defined?

• Linked to bullet 1.

How should the Commission’s Guideline on the details of the various categories of variations to the terms of marketing authorisations for medicinal products for human use and veterinary medicinal products (2010/C 17/01) that supports the Variations Regulation (Commission Regulation (EC) No 1234/2008) be adapted?

• What are the challenges of implementing this in all ICH regions?
• Is there a need to differentiate between chemical and biological

products?

Questions, continued

• Question from previous presentation

(expanded protocols): what needs to be in ICH Q12 to enable such expanded approaches in all regions?